Commitment to the Code of Conduct

The Board, management and all employees of the Company are committed to implementing the Company’s core principles and values stated in this Code of Conduct when dealing with customers, clients, government authorities, creditors and the community as whole as well as other employees.

Responsibilities to Shareholders and the Financial Community Generally

The Company is committed to delivering value to its shareholders and to representing the Company’s growth and progress truthfully and accurately. The Company also complies with the spirit as well as the letter of all laws and regulations that govern shareholders rights.

The Company is committed to safeguarding the integrity of financial reporting. The Company will prepare and maintain its accounts fairly and accurately in accordance with the accounting and financial reporting standards that represent the generally accepted guidelines, principles, standards, laws and regulations of the country in which the company conducts its business.

Responsibilities to Clients, Customers and Consumers

Each employee has an obligation to use their best efforts to deal in a fair and responsible manner with each of the Company’s clients, customers and consumers. Each employee will assist the Company in the delivery of superior service and product quality to each client, customer and consumer and will follow the Company’s procedures.

The Company for its part is committed to providing clients, customers and consumers with fair value.

Employment Practices

The Company will:

Provide a workplace that is safe for employees and that complies with the spirit as well as the letter of workplace health and safety laws.

Promote equal opportunity for all employees at all levels of the Company irrespective of colour, race, gender, age, ethinicity or religious beliefs.

Provide equal opportunity to all qualified individuals in recruitment, compensation, promotion, training and other employment practices.

Recognize the need from time to time to give or accept customary business courtesies in accordance with ethical business practices, however, employees will not solicit such courtesies and will not accept gifts, services, benefits or hospitality that might influence, or appear to influence, the employee’s conduct in representing the Company.

Not tolerate the offering or acceptance of bribes, inducements or unauthorized commissions by any of its employees or officers.

Not tolerate the misuse of Company assets or resources and employees will not use such assets or resources for their own benefit.

Not tolerate employees being under the influence of illegal drugs or alcohol while on Company premises or while at work off Company premises.

Unless otherwise agreed in writing between the Company and the employee, expect employees to work exclusively for the Company.

Responsibilities to the Community

The Environment

The Company is committed to conducting its business in accordance with the spirit and letter of all applicable environmental laws and regulations.

Community Activities

All employees are encouraged to engage in activities beneficial to their local community. While normally these activities should occur outside work hours, employees may occasionally engage in community activities during work hours with the approval of the Board Member / Manager of H.R., as long as the activities do not interfere with the employee’s responsibilities.

Donations and Sponsorship

The Company does encourage all employees to make donations to community organizations from their personal funds. However, it should be made clear that all such donations are from the employee personally and not from the Company.

Responsibility to the Individual

Privacy

The Company receives private information from its employees. Unless required by law, such personal information will not be shared with a third party without the consent of the employees. Within the Company, personal information on employees will only be provided on a “need to know” basis and will only be used for the purpose for which it was intended.

Similarly, employees will often be furnished with personal information from clients, customers, consumers and investors. Unless required by law, such personal information will not be shared with and third party without the consent of the person providing the information.

Confidential Information

All employees must maintain the confidentially of business information and protect it from any disclosure. This obligation of confidentiality applied while an employee as well as after ceasing to be an employee of the Company.

Information that must be kept confidential includes internal, confidential or proprietary information related to the Company’s business, technological and other knowledge, processes, computer passwords, computer software, product formulations, business strategies and plans, and information concerning the Company’s operations, customers, vendors, suppliers and employees.

Conflicts of Interest

Employees and Directors must avoid conflicts between personal interests and the interests of the Company, or even the semblance of such interests. Where an Employee or Director is concerned that there may be a conflict of interest it should be discussed with the Company Secretary as soon as possible.

How the Company Monitors and Ensures Compliance with its Code

The Board, management and all employees of the Company are committed to implementing this Code of Conduct. Therefore, it is up to each individual to comply with the Code and they will be accountable for such compliance. Where an employee is concerned that there has been a violation of this Code, it can be reported in good faith to the Company Secretary. While a record of such reports will be kept by the Company for the purposes of the investigation, the report may be made anonymously. No one making such a report will be subject to any form of retribution.

The disciplinary measures that may be imposed for violations of this Code include, but are not limited to, counseling, verbal or written reprimands, warnings, suspension without pay, demotion, reduction in salary, termination of employment or restitution.

Code of Practices and Procedures for Fair Disclosures of Un-Published Price Sensitive Information:

1. INTRODUCTION

The Board of Directors of Country Condo’s Limited (“The Company”) whose securities are listed on Bombay Stock Exchange & National Stock Exchange of India, has formulated this code of Practices and Procedures (the “code”) for fair and continuous disclosure of Unpublished Price Sensitive Information (UPSI) in the market that it would follow in order to adhere to each of the principles as stated in schedule A of the Securities and Exchange Board of India (prohibition of Insider Trading) Regulations, 2015 (“the regulations”) to prevent Insider Trading and to preserve confidentiality of Un-published price sensitive information.

2. DEFINITIONS

In these regulations, unless the context otherwise requires, the following words, expressions and derivations there from shall have the meanings assigned to them as under:–

c) “Compliance officer” means any senior officer, designated so and reporting to the board of directors or head of the organization in case board is not there, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under these regulations and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of unpublished price sensitive information, monitoring of trades and the implementation of the codes specified in these regulations under the overall supervision of the board of directors of the listed company or the head of an organization, as the case may be

d) "Connected Person" means,-

a) any person who is or has during the six months prior to the concerned act been associated with a Company, directly or indirectly, in any capacity including by reason of frequent communication with its officers or by being in any contractual, fiduciary or employment relationship or by being a director, officer or an employee of the Company or holds any position including a professional or business relationship between himself and the Company whether temporary or permanent, that allows such person, directly or indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access

b) Without prejudice to the generality of the foregoing, the persons falling within the following categories shall be deemed to be connected persons unless the contrary is established, -

c) an immediate relative of connected persons specified in clause (i); or

d) a holding company or associate company or subsidiary company; or

e) an intermediary as specified in section 12 of the Act or an employee or director thereof; or

f) an investment company, trustee company, asset management company or an employee or director thereof; or

g) an official of a stock exchange or of clearing house or corporation; or

h) a member of board of trustees of a mutual fund or a member of the board of directors of the asset management company of a mutual fund or is an employee thereof; or

i) a member of the board of directors or an employee, of a public financial institution as defined in section 2 (72) of the Companies Act, 2013; or

j) an official or an employee of a self regulatory organization recognized or authorized by the Board; or